U.S. Department of Health and Human Services Designation 

of Additional Members of the Special Exposure Cohort 

under the 

Energy Employees Occupational Illness Compensation Program Act of 2000 

Designating a Class of Employees 

Grand Junction Facilities Site 

Grand Junction, Colorado 

HHS Special Exposure Cohort Designation:
 

Grand Junction Facilities Site, Grand Junction, Colorado 
I. Designation 

I, Sylvia M. Burwell, Secretary of the U.S. Department of Health and Human Services 

(HHS), designate the class of employees defined in Section II of this report for addition to 

the Special Exposure Cohort (SEC), as authorized under the Energy Employees Occupational 

Illness Compensation Program Act of 2000 (EEOICPA), 42 U.S.C. § 7384q. 

 May 20, 2015 [Signature on File] 

Date Sylvia M. Burwell 

II. Employee Class Definition 

All employees of the Department of Energy, its predecessor agencies, and its 

contractors and subcontractors who worked at the Grand Junction Facilities site in 

Grand Junction, Colorado, during the period from February 1, 1975, through 

December 31, 1985, for a number of work days aggregating at least 250 work days, 

occurring either solely under this employment or in combination with work days 

within the parameters established for one or more other classes of employees in the 

Special Exposure Cohort. 

III. Designation Criteria and Recommendations 

Pursuant to 42 U.S.C. § 7384q, for the class defined in Section II of this report, the Secretary 

has determined, and the Advisory Board on Radiation and Worker Health (Board) has 

recommended, that 

(1) it is not feasible to estimate with sufficient accuracy the radiation dose that the class 

received; and 

(2) there is a reasonable likelihood that such radiation dose may have endangered the 

health of members of the class. 

The SEC final rule states in 42 C.F.R. § 83.13(c)(1) that it is feasible in two situations to 

estimate the radiation dose that the class received with sufficient accuracy. First, the rule 

states that radiation doses may be estimated with sufficient accuracy if the National Institute 

for Occupational Safety and Health (NIOSH) has established that it has access to sufficient 

information to estimate the maximum radiation dose, for every type of cancer for which 

radiation doses are reconstructed, that could have been incurred under plausible 

circumstances by any member of the class. Alternatively, radiation doses may be estimated 

with sufficient accuracy if NIOSH has established that it has access to sufficient information 

to estimate the radiation doses of members of the class more precisely than a maximum dose 

estimate. 

NIOSH determined that there is insufficient information to estimate the radiation dose of 

individual members of the class with sufficient accuracy under the two abovementioned 

HHS Special Exposure Cohort Designation: Page 2 

Grand Junction Facilities Site, Grand Junction, Colorado 
situations. The Board, pursuant to 42 U.S.C. § 7384q, advised the Secretary to designate the 

class as an addition to the SEC in a letter received by the Secretary on April 24, 2015. 

IV. Designation Findings 

Infeasibility of Estimating Radiation Doses with Sufficient Accuracy 

The Secretary designates the class of employees covered by this report based upon the 

findings summarized below. 

	 The principal sources of internal radiation exposures after January 31, 1975, included 

potential inhalation and ingestion of natural uranium and thorium and their associated 

progeny, resulting from ore crushing, grinding, and handling operations in the Sample 

Preparation Laboratory. 

	 NIOSH has concluded that there are insufficient internal dosimetry data or air monitoring 

data available to estimate uranium or thorium intakes prior to 1986. Beginning in the 

first quarter of 1986, air monitoring data are available, which are sufficient to bound 

intakes of uranium and thorium until the site internal dosimetry program was fully 

implemented by 1991. 

	 Based on the lack of internal dose monitoring data or air monitoring data for Grand 

Junction Facilities workers during the period from February 1, 1975, through December 

31, 1985, NIOSH has determined that reconstruction of internal dose with sufficient 

accuracy is not feasible. However, NIOSH has identified sufficient information and data 

to support bounding internal dose estimates for the period from January 1, 1986, through 

July 31, 2010, using available air monitoring and bioassay data. 

	 NIOSH finds that it is likely feasible to reconstruct internal dose from radon gas and its 

progeny for the Grand Junction Facilities workers with sufficient accuracy from February 

1, 1975, through July 31, 2010. 

	 Using a combination of the worker exposures that were reported to the Atomic Energy 

Commission and the U.S. Department of Energy in the form of annual reports, and the 

more than 15,000 external dosimetry monitoring results that were located after the 

original SEC-00175 evaluation report was issued, NIOSH has sufficient information to 

reconstruct external dose with sufficient accuracy for the period from February 1, 1975, 

through July 31, 2010. 

	 NIOSH finds that it is likely feasible to reconstruct occupational medical dose for Grand 

Junction Facilities workers with sufficient accuracy from February 1, 1975, through July 

31, 2010, by using the Technical Information Bulletin, Dose Reconstruction from 

Occupational Medical X-Ray Procedures (ORAUT-OTIB-0006). 

	 Although NIOSH found that it is not possible to reconstruct internal radiation doses for 

the proposed class, NIOSH intends to use any monitoring data that may become available 

HHS Special Exposure Cohort Designation: Page 3 

Grand Junction Facilities Site, Grand Junction, Colorado 
for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals 

employed at Grand Junction Facilities from February 1, 1975, through December 31, 

1985, but who do not qualify for inclusion in the SEC, may be performed using these data 

as appropriate. 

	 Therefore, pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH has concluded that there is 

insufficient information to either: (1) estimate the maximum radiation dose, for every 

type of cancer for which radiation doses are reconstructed, that could have been incurred 

under plausible circumstances by any member of the class; or (2) estimate the radiation 

doses of members of the class more precisely than a maximum dose estimate for the 

period at Grand Junction Facilities from February 1, 1975 through December 31, 1985. 

	 The Board concurred with NIOSH’s recommendation to add the proposed class of 

workers to the SEC. 

Health Endangerment 

The Secretary established the health endangerment determination for the class of employees 

covered by this report based upon the findings summarized below. 

(1)	 Pursuant to 42 C.F.R. § 83.13(c)(3), NIOSH established that there is a reasonable 

likelihood that such radiation doses may have endangered the health of members of 

the class. Pursuant to 42 C.F.R. § 83.13(c)(3)(ii), NIOSH specified a minimum 

duration of employment to satisfy this health endangerment criterion as “having been 

employed for a number of work days aggregating at least 250 work days within the 

parameters established for this class or in combination with work days within the 

parameters established for one or more other classes of employees in the Cohort.” 

(2)	 NIOSH did not identify any evidence from the petitioners or from other resources that 

would establish that the class was exposed to radiation during a discrete incident likely 

to have involved exceptionally high-level exposures, such as a nuclear criticality 

incident, as defined under 42 C.F.R. § 83.13(c)(3)(i). 

(3)	 The Board concurred with NIOSH’s finding that the health of the class may have been 

endangered and defined the class according to the 250-work day requirement specified 

under 42 C.F.R. § 83.13(c)(3)(ii). 

V.	 Effect and Effective Date of Designation 

The Secretary submits this report on the designation of one additional class to the SEC for 

review by Congress, pursuant to 42 U.S.C. §§ 7384l(14)(C)(ii) and 7384q(c)(2)(A), as 

amended by the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 

2005, Pub. L. No. 108-375 (codified as amended in scattered sections of 42 U.S.C.). 

Pursuant to 42 U.S.C. § 7384l(14)(C)(ii), as amended by the Ronald W. Reagan National 

Defense Authorization Act for Fiscal Year 2005, Pub. L. No. 108-375 (codified as amended 

HHS Special Exposure Cohort Designation: Page 4 

Grand Junction Facilities Site, Grand Junction, Colorado 
in scattered sections of 42 U.S.C.), the designation in this report will become effective 30 

days after the date of this report’s submission to Congress “unless Congress otherwise 

provides.” 

VI. Administrative Review of Designation 

The health endangerment determination of the designation provided in this report may be 

subject to an administrative review within HHS, pursuant to 42 C.F.R. § 83.18(a). On the 

basis of such a review, if the Secretary decides to expand the class of employees covered by 

this designation, the Secretary would transmit a supplementary report to Congress providing 

the expanded employee class definition and the criteria and findings on which the decision 

was based. 

HHS Special Exposure Cohort Designation: Page 5 

Grand Junction Facilities Site, Grand Junction, Colorado